Privacy Policy

This Privacy Policy explains how Jlance ("we", "us") collects, uses, shares and protects personal data. Jlance is a stand-alone product licensed under Jentry Infinite Limited (RC 9623613). We handle personal data in line with the Nigeria Data Protection Act 2023 ("NDPA"), the General Application and Implementation Directive 2025 ("GAID") issued by the Nigeria Data Protection Commission ("NDPC"), and other applicable Nigerian law.

This policy sits under the Jentry Infinite Master Terms of Service & Use Policy and works together with the Jlance Terms of Use and Cookie Policy. We wrote it in plain language so that everyone can understand it.

1. Who is responsible for your data

• Data controller: Jlance, a stand-alone product licensed under Jentry Infinite Limited (RC 9623613), Abuja, Nigeria.
• Data Protection Officer (DPO): [privacy@ address].

2. What we collect and why

We collect this from you directly, from your use of Jlance, and from third parties such as sign-in or verification providers you choose to use. We collect only what we need for these purposes.

How we apply each lawful basis:

• Consent. It is freely given, specific, informed and unambiguous. Nothing is pre-ticked, and you can withdraw consent as easily as you gave it.
• Contract. We need the data to create your account and deliver your project.
• Legal obligation. We need the data to meet tax, accounting, anti-fraud and other legal duties.
• Legitimate interests. We use this only after weighing our interests against your rights and freedoms. You can object at any time.

3. Sensitive personal data

We do not ask for sensitive personal data. Under the NDPA this includes genetic and biometric data, race or ethnic origin, religious or similar beliefs, health status, sex life, political opinions and trade union membership. If an identity check or a specific project needs any of it, we will ask for your explicit consent first, collect only what is needed, and add extra safeguards. Please do not upload sensitive data to a project unless the project requires it.

4. Other ways we use data

• To comply with laws, respond to lawful requests and enforce our Terms.
• To detect, investigate and prevent fraud, abuse and security incidents.
• To create anonymised or aggregated statistics that do not identify you.

We do not sell your personal data.

5. How AI features use your data

Jlance sends the content you enter into AI features to third-party AI model providers, through their business APIs, so they can generate outputs for you.

• We share only what is needed for the task.
• During the beta, the AI provider's free tier applies. Under its terms, the provider may use inputs and outputs to improve its products, and human reviewers may read them. Do not enter confidential, personal or sensitive information into AI features.
• We assess the privacy risks of AI processing and review them as Jlance changes.
• AI outputs that affect matching, pricing or milestone decisions are reviewed by Jlance staff before they take effect.
• You have the right not to be subject to a decision based solely on automated processing that has legal or similarly significant effects on you, and to ask for human review.

6. Who we share data with

• Other users. Clients and assigned Experts see the project data and profile details needed to work together. Experts do not see Client data for projects they are not assigned to.
• Service providers (data processors). Hosting and storage, payment processing, email and messaging, analytics, customer support and AI providers. Each is bound by written terms or a data processing agreement. For AI providers, see section 5.
• Jentry Infinite group. Our licensor, Jentry Infinite Limited, and its group companies that support Jlance, under the same protections.
• Authorities and advisers. Regulators, courts, law enforcement, auditors and professional advisers, where the law requires or to protect rights.
• Business transfers. A buyer or successor, if Jlance or Jentry Infinite Limited is restructured or sold. We will tell you first where required.

7. Transfers outside Nigeria

Some providers, including AI and hosting providers, process data outside Nigeria. We transfer personal data abroad only where:

• the destination offers an adequate level of protection under the NDPA and NDPC rules;
• we have appropriate safeguards in place, such as standard contractual clauses or binding corporate rules; or
• another ground in the NDPA applies, such as your informed consent or necessity to perform your contract.

You can ask us for details of the safeguards we use at [privacy@ address].

8. How long we keep data

We may keep data longer where needed for a legal claim or legal duty. After that we delete or anonymise it.

9. Security, accountability and breaches

• We use technical and organisational measures suited to the risk, including encryption in transit, role-based access controls, separation of the Client, Expert and Admin portals, activity logging, vendor checks and staff confidentiality duties.
• We keep records of our processing and carry out data privacy impact assessments where the law requires.
• Where the law applies to us, we register with the NDPC and file our annual compliance audit return.
• If a personal data breach is likely to put your rights and freedoms at risk, we will notify the NDPC within 72 hours of becoming aware of it.
• Where the risk to you is high, we will also tell you immediately, explaining what happened, the likely effects and what we are doing about it.

No system is completely secure, but we work to keep your data safe.

10. Your rights

Under the NDPA you can:

• be told how your data is used, and ask for confirmation and a copy of it;
• ask us to correct inaccurate or incomplete data;
• ask us to delete data, or restrict its use, in the cases the law provides;
• object to processing based on our legitimate interests, and to direct marketing at any time;
• receive your data in a structured, commonly used, machine-readable format, and ask us to send it to another controller, where it applies;
• withdraw consent at any time, without affecting earlier lawful processing; and
• not be subject to solely automated decisions with significant effects, and ask for human review.

To use these rights, email [privacy@ address]. We may ask you to verify your identity. We respond without undue delay and within one month, free of charge, unless a request is manifestly unfounded or excessive.

11. Complaints and grievances

If you believe we have mishandled your personal data, first send us a Standard Notice to Address Grievance (SNAG) at [privacy@ address]. We will acknowledge it within [3] working days and respond within [14] days. If you are not satisfied, you can complain to the Nigeria Data Protection Commission (www.ndpc.gov.ng).

12. Direct marketing

We send marketing messages only with your opt-in consent. Every message has an unsubscribe link, and you can also opt out in your account settings or by emailing us.

13. Children

Jlance is for people aged 18 and over, and is not directed at children. Under the NDPA a child is a person under 18. When you sign up, you confirm that you are 18 or older, and we rely on that confirmation. We do not knowingly collect children's data. If we learn that an account belongs to a child, we may suspend it and will delete the child's data in line with the law. If you believe a child has given us data, contact us at [privacy@ address].

14. Third-party links

Jlance may link to other sites or services. Their privacy practices are their own, and we are not responsible for them.

15. Changes to this policy

We may update this policy as Jlance grows. For material changes we will give notice by email or in the platform before they take effect, and we will update the effective date above.

16. Contact

Jlance, licensed under Jentry Infinite Limited (RC 9623613), Abuja, Nigeria. Email: [privacy@ address].